[802SEC] re: Reply Comments on 5 GHZ NPRM
Dear EC members,
After the approval of 18-03-0061-00-0000_802_18_Rep_Cmts_ET-03-122.doc
by 802.18, 802.11, and 802.15 in Singapore, and its submittal for the
5 day EC pre-filing review, an issue was raised by a member of 802.16
(who did not attend our meeting in Singapore).
There has been some discussion amongst the parties, with Roger Marks'
participation, and in the interest of addressing the concern expressed
by the member of 802.16, I have proposed to add a paragraph, with an
appropriate heading to the document as an editorial change.
(text follows within ***** lines, with the 1st sentence being the heading)
*****
The Commission should endeavor to identify additional spectrum for high power
outdoor point-point and point-multipoint broadband distribution.
While we understand that the Commission is bound by the ITU Radio Regulations
regarding the bands under consideration in the instant Proceeding, we (consistent
with our previously filed comments) share the concerns of the License-Exempt
Alliance (LEA) regarding the Commission's assumption of the adequacy of the
100 MHz at 5.725-5.825 MHz for higher-power outdoor operations. While "out of
scope" in the instant Proceeding, we encourage the Commission to remain
committed to finding ways to provide increased capacity for such services through
another proceeding.
*****
I would hasten to point out the following to the members of the EC:
1)This text is ENTIRELY in harmony/agreement with text on EXACTLY
this issue that was contained within the original comments of 802,
that were approved at the July Plenary in SFO by 802.18, 802.11,
802.15, 802.16, and the EC, and were filed with the FCC.
(see
http://www.ieee802.org/Regulatory/Meeting_documents/2003_July/18-03-0041-01-0000_802_Cmts_ET-03-122_Formal.doc
at 18-20)
2) There has been no objection from any of the members of 802.18
to the addition of this text (in fact, there has been support
expressed by those members of 802.18 who did comment).
3)The addition of this text would not prejudice the interests of
any of the other wireless WGs.
4)Roger is aware of my intent, and I believe he supports it as
an effort to accomodate a concern expressed by one of his members.
Since the substance of this addition has already been approved
and filed with the FCC in our original comments, I consider the
addition of this text in an effort to extend the consensus on
our reply comments an appropriate editorial modification to the
approved document.
Since the filing deadline on this document is midnight, end of
Sept. 23, EDT, I strongly urge you all to allow this change to
go forward. Were it not consistent with our previously filed
comments, I would think that the "5 day clock" would need to be
reset, but since it IS TOTALLY consistent with what the EC has
previously approved, I don't believe that action (which would
preclude the filing of the modified document) should be required.
Respectfully submitted,
Carl R. Stevenson
Chair, IEEE 802.18 Radio Regulatory Technical Advisory Group
610-965-8799 (home office)
610-712-3217 (fax mailbox)
610-570-6168 (cellphone)
Short Message Service: 6105706168@voicestream.net
carl.stevenson@ieee.org